[FCSF2016]

We have sent a customer ARM rate notices in accordance with 1026.20(c) and (d) for an upcoming rate adjustment. It is less than 30 days before the new rate goes into effect and the loan officer would like to discount the new rate by .50%. Can we do this without additional disclosures?

Topic

[rcooper]

It is expected that lenders know the new rate when the disclosures go out. The regulation doesn’t address how to handle a situation like you’ve described.

Why is the discount being given now this late in the process? My concern is that it would set a precedent for similar actions in the future. Please share any additional information that will help me understand the situation better.

[Author]

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